In re: Agilon Health, Inc. 2025 Securities Litigation — Entry #21: Letter regarding Joint Stipulation and Proposed Order for Schedule to File Plaintiff's Amended Complaint and Defendants' Responses Thereto and Other Relief by…

Case 1:25-cv-07167-HG              Document 21-1             Filed 05/04/26   Page 1 of 4 PageID #: 201


                                 UNITED STATES DISTRICT COURT
                                 EASTERN DISTRICT OF NEW YORK

 JEREMY VANDERSLUIS, Individually
 and on behalf of all others similarly
 situated,
                                                             Case No: 1:25-cv-07167-HG
            Plaintiff,
 vs.

 AGILON HEALTH, INC., STEVEN J.
 SELL, and JEFFREY SCHWANEKE,

            Defendants.


               JOINT STIPULATION AND [PROPOSED] ORDER FOR (1) SCHEDULE
                        TO FILE PLAINTIFF’S AMENDED COMPLAINT
               AND DEFENDANTS’ RESPONSE THERETO AND (2) OTHER RELIEF

           Lead Plaintiff HR & Sons LLC (“Plaintiff”) and Defendants agilon health, inc., Steven Sell, and

Jeffrey Schwaneke (“Defendants,” and collectively with Plaintiff, the “Parties”) hereby stipulate and agree as

follows:

           WHEREAS, on April 28, 2026, the Court entered an Order that, among other things, appointed HR

& Sons LLC as Lead Plaintiff, approved its selection of The Rosen Law Firm, P.A. as Lead Counsel, and

directed the Parties to meet-and-confer and submit a proposed schedule for the filing of an amended complaint

and briefing schedule for any responses thereto on or before May 12, 2026;

           WHEREAS, the Parties have met and conferred and agreed on a schedule for Plaintiff to file its

Amended Complaint (“AC”) and for Defendants’ responses thereto;

           NOW, THEREFORE, the Parties hereby stipulate and agree, and respectfully request that the Court

enter an Order, as follows:

           1. Plaintiff shall file its AC on or before June 29, 2026;

           2. Defendants shall move to dismiss, answer, or otherwise respond to the AC on or before August

28, 2026;


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Case 1:25-cv-07167-HG            Document 21-1            Filed 05/04/26       Page 2 of 4 PageID #: 202


        3. If Defendants move to dismiss the AC, Plaintiff shall file its opposition to the motion to dismiss on

or before October 27, 2026, and Defendants shall file their reply brief in support of their motion to dismiss

on or before December 3, 2026; and

        4. The caption shall be renamed to: In re: agilon health, inc. 2025 Securities Litigation.

        Respectfully submitted this 4th day of May, 2026.


 THE ROSEN LAW FIRM, P.A.                                 ALSTON & BIRD

 /s/ Matthew Siben                                        /s/ Elizabeth Gingold Clark
 Matthew Siben, Esq.                                      Elizabeth Gingold Clark
 355 South Grand Avenue, Suite 2450                       Registration No. 4799409
 Los Angeles, CA 90071                                    Courtney Quirós (admitted pro hac vice)
 Telephone: (213) 785-2610                                90 Park Avenue
 Facsimile: (213) 226-4684                                New York, NY 10016-1387
 [email protected]                                    Telephone: (212) 210-9400
                                                          Facsimile: (212) 210-9444
 Phillip Kim, Esq.                                        [email protected]
 Laurence M. Rosen, Esq.                                  [email protected]
 275 Madison Avenue, 40th Floor
 New York, New York 10016                                 Counsel for Defendants
 Telephone: (212) 686-1060
 Facsimile: (212) 202-3827
 [email protected]
 [email protected]

 Lead Counsel for Plaintiff HR & Sons LLC
 and the Putative Class


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Case 1:25-cv-07167-HG    Document 21-1       Filed 05/04/26   Page 3 of 4 PageID #: 203


IT IS SO ORDERED this _____ day of ______________, 2026.


                                      ______________________________________
                                      HONORABLE HECTOR GONZALEZ
                                      UNITED STATES DISTRICT JUDGE


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Case 1:25-cv-07167-HG         Document 21-1        Filed 05/04/26       Page 4 of 4 PageID #: 204


                                 CERTIFICATE OF SERVICE

       I hereby certify that on this 4th day of May, 2026, I electronically filed the foregoing

document with the Clerk of the Court using the CM/ECF system, which will automatically send

an email notification of such filing to all attorneys of record in the above-referenced action.

                                                    ALSTON & BIRD

                                                    /s/ Elizabeth Gingold Clark
                                                    Elizabeth Gingold Clark
                                                    [email protected]
                                                    90 Park Avenue
                                                    New York, NY 10016-1387
                                                    Telephone: (212) 210-9400
                                                    Facsimile: (212) 210-9444